The purpose of this policy is to notify the visitors of our website, journalists that send accreditation requests, visitors that subscribe to the newsletter and other persons with the purposes and principles relating to processing of personal data in Kulturno društvo Veseli dihurčki.
This policy also further clarifies the conditions for consent, how long we keep your data, the rights of natural persons regarding the processing of personal data and the rights of natural persons in the event that the regulations on the safety of personal data are infringed.
Per the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) the following information are part of this Policy:
• contact information of Kulturno društvo Veseli dihurčki,
• purposes, basis and types of processing of personal data,
• how long we keep personal data,
• rights of natural persons regarding the processing of personal data,
• right to file a complaint about the processing of personal data.
2. Controller of personal data
The controller of personal data is Kulturno društvo Veseli dihurčki which treats personal data in accordance with its legal and regulatory rules.
Information about the controller:
Kulturno društvo Veseli dihurčki, Barvarska steza 9, 1000 Ljubljana, registration number: 2150727000, VAT: SI62584731, registered at UE Ljubljana on 30.11.2005, chairman Matej Ahlin.
3. Personal data that Kulturno društvo Veseli dihurčki collects
Kulturno društvo Veseli Dihurčki collects the following categories of personal data:
1. Data you submit yourself
• when you subscribe to our newsletters,
• when you apply for accreditation,
• when you browse through our content,
• when you ask us questions.
2. Data you create while using our services
• mostly when you post a question, comment or rate our events.
4. The purposes and legal grounds for the processing of data
In accordance with regulations on the protection of personal data Kulturno društvo Veseli dihurčki as the collector of personal data must ensure for any kind of transmission of personal data, that it is later possible to determine what categories of personal data were transmitted, to who, when and on which legal grounds, for which purpose and/or reasons and/or what kind of procedure, except if another law states otherwise.
Processing necessary for the purpose of the legitimate interests pursued by Kulturno društvo Veseli dihurčki:
Kulturno društvo Veseli dihurčki can process data on the basis of the legitimate interest that it pursues or is pursued by a third party, except where such interests are overriden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. When further usage of data is in question Kulturno društvo Veseli dihurčki performs an assesment in accordance to the General Data Protection Regulation (GDPR).
In accordance to GDPR direct marketing is a legitimate interest.
On the basis of legitimate interest Kulturno društvo Veseli dihurčki can contact data subjects in order to determine their satisfaction with the services even when this is not strictly necessary. Kulturno društvo Veseli dihurčki weighs this interest with the interest of data subjects and does not contact those subject that have objected to this.
Based on legitimate interest Kulturno društvo Veseli dihurčki can proccess data in a strictly necessary and proportionate scope.
Processing on the grounds of consent given by the data subject:
Kulturno društvo Veseli dihurčki may ask data subjects to give their consent to the processing of personal data needed to assess certain personal aspects of the data subject, e.g. the analysis of personal tastes, interests and behavior of a data subject (profiling) for the purpose of accommodated offers of services to the subject including informing, direct marketing and market research. In such cases the processing of personal data is performed in regards with the scope of personal data, intent and channels for informing which the data subject has agreed to, up untill the withdrawal of consent. The informing about the processing of personal data is performed in the way which the data subject decided on in the consent.
Consent is valid only when given by a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of the data subject's agreement to the processing of personal data relating to him or her, such as by a written statement, including by electronic means, or an oral statement.
The data subject has the right to withdraw his or her consent at any time in the same way that it was given, or in another way determined by Kulturno društvo Veseli dihurčki whereas Kulturno društvo Veseli dihurčki has the right to identify such a subject. Withdrawal or change of consent only affects data which is processed on the grounds of consent. The last data subject's consent that Kulturno društvo Veseli dihurčki receives is valid. The revocation of consent does not effect the lawfulness of processing which was carried out on the grounds of consent unill its revocation.
5. How long we keep your personal data?
We store your personal data as long as they are necessary for the realization of the intent of their processing or untill you revoke your consent for the processing of personal data for individual or all purposes of processing.
Clearance data and connected contact data about data subjects can be stored untill full payment and/or as long as the limitation periods of each individual claim are running (one to five years). Receipts are stored for 10 years after the end of the year in which they were issued in accordance with the Value Added Tax Act.
Personal data processed on the grounds of your consent is stored for the shortest possible time period or untill you revoke your consent. The revocation of consent does not effect the lawfulness of processing which was carried out on the grounds of consent unill its revocation. After the purpose of processing is fulfilled the data is deleted, destroyed, blocked or made anonymous, unless law states otherwise.
6. Who processes personal data?
Personal data of data subjects can be processed by the following:
• members of Kulturno društvo Veseli dihurčki (in line with their contractual obligations and regulations),
• public authorites when exercising their legal obligations (e.g. Financial Administration of the Republic of Slovenia),
• contractual processors of personal data with which Kulturno društvo Veseli dihurčki decided a contract on the processing of personal data,
• other persons if you have given your consent,
• other persons only if they have a legal basis.
In the above mentioned users are also companies that provide Kulturno društvo Veseli dihurčki with technical support (e.g. webmasters, developers of software solutions, etc.) and persons and/or companies that provide Kulturno društvo Veseli dihurčki with services such as accounting, postal services, legal services, etc.
7. Rights of natural persons on which personal data apply
Kulturno društvo Veseli dihurčki provides information on action taken on a request about the rights to the data subject without undue delay and in any event within one month of receipt of the request. That period my be extended by two further months where necessary, taking into account the complexity and number of requests. Kulturno društvo Veseli dihurčki shall inform the data subject of any such extensions within one month of receipt of the request, together with the reasons for the delay.
Kulturno društvo Veseli dihurčki accepts demands on the rights of data subjects via e-mail email@example.com or by mail to Kulturno društvo Veseli dihurčki, Barvarska steza 9, 1000 Ljubljana, Slovenia.
Where the data subject makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the data subject.
Where Kulturno društvo Veseli dihurčki has reasonable doubts concerning the identity of the natural person making the request about one of his/her rights, Kulturno društvo Veseli dihurčki may request the provision of additional information necessary to confirm the identity of the data subject.
Where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, Kulturno društvo Veseli dihurčki may either:
– charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the actions requested; or
– refuse to act on the request.
Kulturno društvo Veseli dihurčki grants the following rights to natural persons regarind the processing of personal data:
a) right of access,
b) right of rectification,
c) right to be forgotten,
d) right to restriction of processing,
e) right of portability,
f) right to object.
a) right to access
The data subject has the right to obtain from Kulturno društvo Veseli dihurčki confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
- the purposes of the processing,
- the categories of personal data concerned,
- the recipients or categories of recipient to whom the personal data have been or will be disclosed,
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period,
- the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing,
- the right to lodge a complaint with a supervisory authority,
- where the personal data are not collected from the data subject, any available information as to their source,
- the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
If a data subject demands so, Kulturno društvo Veseli dihurčki will provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, Kulturno društvo Veseli dihurčki may charge a reasonable fee based on administrative costs.
b) right to rectification
The data subject has the right to obtain from Kulturno društvo Veseli dihurčki without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data has the right to have incomplete personal data completed, including by means of providing a supplementary statement.
c) right to erasure
The data subject has the right to obtain from Kulturno društvo Veseli dihurčki the erasure of personal data concerning him or her without undue delay and Kulturno društvo Veseli dihurčki has the obligation to erase personal data without undue delay where one of the following grounds applies:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the data subject withdraws consent on which the processing is based and where there is no other legal ground for the processing;
- the data subject objects to the processing pursuant and there are no overriding legitimate grounds for the processing,
- the personal data have been unlawfully processed;
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
- the personal data have been collected in relation to the offer of information society services,
Where Kulturno društvo Veseli dihurčki has made the personal data public and is obliged to erase the personal data, Kulturno društvo Veseli dihurčki taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
d) right to restriction of processing
The data subject has the right to obtain from Kulturno društvo Veseli dihurčki restriction of processing where one of the following applies:
- the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
- Kulturno društvo Veseli dihurčki no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
- the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.
e) pravica do prenosljivosti podatkov
The data subject has the right to receive the personal data concerning him or her, which he or she has provided to Kulturno društvo Veseli dihurčki in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
- the processing is based on consent,
- the processing is carried out by automated means.
f) pravica do ugovora
The data subject has the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her. Kulturno društvo Veseli dihurčki shall no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
You can exercise the above stated rights with a written demand addressed to Kulturno društvo Veseli dihurčki, Barvarska steza 9, 1000 Ljubljana, Slovenia or via e-mail firstname.lastname@example.org. In the same way you can permanently or temporarely, completely or partially cancel your consent for the processing of personal data, if you have given such a consent.
8. Right to complaint
In Kulturno društvo Veseli dihurčki we strive to protect your personal data with dilligence and appropriate technological and organizational means of transmission protection and filing of personal and other confidential data. Nevertheless we would like to inform you that you have the right to lodge a complaint if you feel that your personal data is not processed according to the rules on protection of personal data.
Data subjects can lodge a complaint about the processing of personal data via e-mail email@example.com or by mail on Kulturno društvo Veseli dihurčki, Barvarska steza 9, 1000 Ljubljana, Slovenia.
Additionally data subjects on which personal data apply may lodge a complaint directly to the supervisory authority – Informacijski pooblaščenec RS, Zaloška 59, 1000 Ljubljana, Slovenia – if they feel their personal data is not processed according to Union or Member state rules on protection of personal data.
If a data subject exercised his or her right to access at Kulturno društvo Veseli dihurčki and feels that he or she did not receive the right data or did not receive all the data, he or she can lodge a complaint to Kulturno društvo Veseli dihurčki before lodging a complaint to the supervisory authority, in 15 days. Kulturno društvo Veseli dihurčki must decide on the new complaint in five working days.
9. Ensuring accurate, complete and up-to-date data
Kulturno društvo Veseli dihurčki strives to ensure accurate and up-to-date personal data which can be achieved in line with regulations and/or data subjects' consent. Complete and up-to-date data can only be used for purposes determined by this Policy and no other means unless you have given your consent.
Kulturno društvo Veseli dihurčki is aware that the privacy of our users is crucial, therefore we treat their personal data with care and dilligence and in accordance with rules and regulations of the Republic of Slovenia and internal rules of Kulturno društvo Veseli dihurčki. Accesss to personal data is granted only to authorized personnel and contractual processors and in the scope and intent that is needed to to provide our services.
In the case of major updates or changes of how Kulturno društvo Veseli dihurčki uses personal data, data subject will be notified about this via a notice on our website or by e-mail (if a consent for this is given), beforehand.
Kulturno društvo Veseli dihurčki recomends to users that they regularely inspect this policy and be informed on how Kulturno društvo Veseli dihurčki protects their privacy.
11. Additional information
For additional information about the processing of personal data or if you have suggestions for improvements you can contact us via firstname.lastname@example.org or write to us: Kulturno društvo Veseli dihurčki., Barvarska steza 9, 1000 Ljubljana, Slovenia.
This Policy comes to effect on 25.05.2018 and is in use until its revoked or its provisions are changed.